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OSHA at 40: Taking on a Mid-life Crisis?

Posted by Shivi Kakar

Oct 11, 2010 1:00:07 AM

Bruce Groves - CIH

In July, David Michaels, Assistant Secretary of Labor for Occupational Safety and Health, published a memo to his staff at OSHA highlighting several new approaches that OSHA is using (or planning to use) in its effort to protect workers.  Dr. Michaels is building on the progress of his predecessors and reinforcing some of the weak links in the system created both by Congress and former administrations. In his recent letter, Dr. Michaels reviews some legacy issues that limit OSHA-influence in creating safer workplaces such as

  • OSHA has only 2,000 inspectors responsible for the health and safety of 130 million workers at 7 million worksites

  • OSHA fines are too small to have an adequate deterrent effect

  • OSHA standards provide limited protection to whistleblowers from retaliation

  • OSHA occupational exposure standards have been established for only a small percentage of chemicals used in US workplaces (most of those are based on out-of-date science) with a slow and resource-intensive standard-setting process

Dr. Michaels states that OSHA needs to transform how it addresses workplace hazards, and in its relationship to employers and workers. As such he outlines a new strategy that is a clear shift from recent years indicating that there is a “new sheriff in town” and business (ALL businesses) should take heed.  Here are some of my extrapolations and thoughts regarding 6 of these transformational items -- consider how they will affect your business or workplace.
1.       Stronger Enforcement:  Some Employers Need Incentives to Do the Right Thing

OSHA will have more and bigger sticks.  OSHA is redirecting resources to conduct inspections of high risk industries and tasks including ergonomics.

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Topics: Emilcott, OSHA, indoor air quality, health and safety, General Industry H&S, General EHS, Construction H&S, H&S Training, Compliance, worker safety, Occupational Health, Occupational Safety, Lab Safety & Electrical, emergency response training, Occupational Training, Safety Training in Spanish, water safety, small business

Safety Leadership: A Message to Owners and Managers

Posted by Shivi Kakar

Sep 27, 2010 3:04:31 AM

Capt. John DeFillippo, CHMP, EMT-B

Every organization develops a “safety culture”, be it good or bad. It is immediately observable to anyone who cares to look, and more people are – particularly prospective clients and business partners.  When evaluating vendors and business partners, companies with strong safety cultures will steer clear of doing business with companies with poor safety records; the risks and exposures are too great.  In addition to the obvious reasons of possible injury or death to workers or the public, there is the potential for serious damage to a company’s image and reputation should their vendor or subcontractor have an incident or accident.  We’ve all heard some of the stories recently in the news; reporters will highlight a major construction accident and all the players are named, regardless of their culpability.

Government agencies also use strong criteria to evaluate potential vendors. The State of New York has severely tightened up its safety and health requirements following the series of construction accidents that have plagued NYC in recent years.

A company can develop a comprehensive health and safety programs. It can post attention-getting signs and posters warning workers of hazards. It can also provide all manner of safety and personal protective equipment and conduct training for employees. These measures are good, but as soon as a supervisor or company owner walks onto a site ignoring the PPE requirements, all this good goes out the window. “Do as I say, not as I do” is not the way lead. The rules must to apply to all, without exception. Even more importantly, owners and managers should set a proper example. Professional experience has shown me that when management creates and “lives” a proactive safety culture, it will get the best results. It’s the front-line managers and supervisors that make the difference.

And it’s a never ending task. Maybe your company has a few workers who constantly violate the safety rules without any real consequences or discipline. The message being sent is pretty clear: the company doesn’t take safety seriously. Most people realize that the rules are there for a reason; their protection and it’s the law.  However, there will always be a small percentage of people that just don’t get it. Without enforcement of the policies, there is not only the risk of worker injury, but an erosion of the “safety culture” of the organization and a negative impact on morale. Plus, it is the employer and management who will be responsible for any fines or penalties handed out as well as increased insurance premiums, particularly workman’s compensation. Often, they are found personally responsible. Why would anyone risk this?

The point is that paying lip service to safety won’t fly anymore -- proactive is best. There are all kinds of resources to help your company succeed. OSHA even offers free services: and  You may also get help from a trade or professional association that you belong to. Health and safety consulting services from companies like Emilcott who are experienced in honing in on risk and compliance can be a great investment to shift your company onto the right track.

Have you ever worked for a company that has an ineffective or sham health and safety policy? How did it make you or fellow employees feel? Was there a tipping point event that made them switch to being proactive and how did they implement a new, comprehensive program (that worked)?

Image Credit:

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Topics: Personal Protective Equipment, health and safety, General Industry H&S, General EHS, Construction H&S, Emergency Response, H&S Training, Compliance, worker safety, Occupational Health, Occupational Safety, Lab Safety & Electrical, emergency response training, Fire Safety, Occupational Training, Safety Culture, Leadership

Safety & Health Training – A Victim of Its Own Success?

Posted by Shivi Kakar

Jun 14, 2010 1:11:20 AM

Capt. John DeFillippo, CHMP, EMT-B

These are tough economic times and businesses are looking to cut costs and save money. A disturbing trend I have noticed is the willingness of many companies to make cuts in safety programs and employee training in a misguided attempt to improve the bottom line.

Trained workers are safer workers.  The facts bear this out. Shortsighted statements I’ve heard include; “We don’t have problems in that area, so we’re cutting back on training.”, when the training was most likely the reason for the lack of problems.

Often, it is difficult to see how beneficial training can be until you experience the effects of its absence. Negative indications show themselves in higher EMRs, increased workman’s compensation claims, lost production time, and property damage. Only companies actively tracking and trending incidents are likely to realize this. (By the way, such companies would also be the ones least likely to make such cuts in the first place!)

It takes just one serious incident resulting in injuries to quickly eliminate any savings associated with cutting programs and training.  What’s more, most health and safety training is required by regulations, so there is also the risk of fines for non-compliance. These can be hefty and since most companies don’t budget for them, they become an extraordinary cost – right off the bottom line!

At Emilcott, we have seen firsthand the effects that result from a lack of training.  Recently, we were hired by a client who laid-off their safety director a couple years prior.  After starting our work, we informed the client of numerous safety violations throughout their organization. These appeared to be a direct result of the lapse in proper safety training – since they no longer had a safety director to oversee their program.  Through the Emilcott Training Institute, our client was able to receive the training needed to avoid these safety violations – and keep their employees safe and on the job. However, in their attempt to save money, the client ended up spending more in a short period of time just to catch up.

Making drastic H&S budget cuts just never pay off.  As experienced health and safety consultants, we work with our clients to offer solutions when budgets get tight:

  • Outsource until you can hire again – we have provided EHS professionals at our clients’ sites for just this purpose for both short and long term requirements.

  • Prioritize your H&S needs – consider the total reduction in your workforce or operations to determine where you can pull back and where you cannot.

  • Take advantage of training courses open to the public – it may no longer be economically sound to run a training course in-house, but don’t lapse on required courses.

  • Take advantage of FREE resources – many consultants provide lots of free info and OSHA will provide all types of assistance at no cost. As an example, Emicott offers a comprehensive Free Training Needs Assessment at!

  • Pool resources – look toward your industry’s professional organizations or neighboring companies to share services. Maybe a part-time Safety Director is better than none at all.

  • Ask a professional – put together a plan and a program to get you through the lean times

Has your company adjusted their health and safety program for leaner times?

Have you seen a direct effect and how are you compensating?
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Topics: OSHA, health and safety, General Industry H&S, Construction H&S, Emergency Response, H&S Training, Compliance, worker safety, Occupational Health, Occupational Safety, Fire Safety, Occupational Training, Lab Safety, Safety Training in Spanish

Water Safety at Work

Posted by Shivi Kakar

May 24, 2010 2:57:16 AM

Capt. John DeFillippo, CHMP, EMT-B

Does your company have employees that work on, near or over water? Hazardous waste site and emergency response workers, those in the construction trades, surveyors and bridge inspection/repair crews are but a few occupations where this applies. OSHA regulations (29 CFR 1926.106 for example) cover the safety of such workers including training and protective equipment requirements. Other federal and state (USCG and TSA) regulations may also apply to your operation. For example, if you are working over water, such as bridge work, you must have a rescue skiff at the ready, with trained personnel to operate it, in case someone falls in. Working at piers, refineries or other marine facilities may entail very specific security requirements.

Water can be unforgiving of carelessness. As a veteran of the U.S. Coast Guard, an EMT and a licensed captain working in the marine salvage industry, I’ve seen plenty of tragedies on the water. Nearly all were avoidable. Here are some essential questions to help you assess your water safety knowledge:

  • Is everyone wearing personal flotation devices? Are they the right type, worn correctly, and U.S. Coast Guard approved?

  • What is the water temperature? In April in the mid-Atlantic region, the water is about 45 degrees F which means you can last about 15 minutes before hypothermia sets in.

  • Do you understand the risk of hypothermia? Even if the water is at 80 degrees F, it’s the same as being in air of 42 degrees F. And, water removes heat from the body 25 times faster than air of the same temperature.

  • Does everybody know how to swim? What to do if caught in a current? Will they know to swim parallel to the shore or go with it until you out of it? You can't swim against a current, even a gentle one, for very long, so don’t try.

  • If someone does fall in, what’s the plan? Formulating a plan when you hear the splash is too late! Having the proper rescue equipment and understanding how to use it is essential.

  • Who is trained in CPR and Basic First Aid? Knowing what to do in an emergency saves lives! Too many would-be rescuers become victims themselves, so leave water rescue to those who have the training and tools.

  • Is the boat operator trained? Employers who would never think of allowing an untrained person to operate a crane often have no problem letting someone without proper training operate a boat on a navigable waterway. Many states, including New Jersey, now require all operators of power-driven vessels to take an approved Safe Boating Course. Fines can be steep and may get the vessel impounded.

The Emilcott Training Institute offers many training programs that can help keep workers safe, including an 8-hour Water Safety and Boating Basics that is approved by the NJ State Police and recognized in several other states as well. Fall Protection, Water Safety and Red Cross CPR and Basic First Aid are also offered in-house or on-site. If you have ANY questions about water safety at work, give Emilcott a call or comment below.
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Topics: OSHA, Personal Protective Equipment, health and safety, General Industry H&S, Construction H&S, Emergency Response, H&S Training, worker safety, Occupational Safety, emergency response training, Occupational Training, water safety, Water Response Plan

The Regulators Awake: Proposed Changes to the OSHA Hazard Communication Standard

Posted by Shivi Kakar

Oct 13, 2009 6:50:04 AM

Paula Kaufmann, CIH
Both OSHA and the EPA seemed to have recently awoken from their regulatory slumber. OSHA has announced its first major rulemaking during the Obama administration with a proposed change to the agency’s Hazard Communication (HazCom) Standard.  The existing OSHA HazCom Standard provides workers with the right to know the hazards and identities of the chemicals they are exposed to while working, as well as the measures they can take to protect themselves.  This standard was originally adopted in November 1983 and has been enhanced a few times with the latest revision in February 1994.

The proposed changes set the stage for the United States to catch up with the global community in the use of globally consistent methods for chemical hazard classification, hazard labeling, and the format of Material Safety Data Sheets (MSDS).  The proposed changes will align the HazCom Standard with the United Nations Globally Harmonized System of Classification and Labeling (GHS).  The GHS was adopted by the UN in 2003 with a goal of implementation in 2008.   Most multinational companies have been following both the global system and the current OSHA Hazard Communication Program in recent years.  The US Department of Transportation has already modified the DOT requirements to make them consistent with international UN transportation requirements and the GHS.  Now it is time for OSHA.

The proposed changes will significantly improve the quality and consistency of information provided to workers, employers and chemical user by having a standardized approach to identifying the hazard, labeling the hazard on containers and equipment, and documentation of the hazard on a MSDS.  The most pronounced change that chemical purchasers and workers will see is a consistent hazard warning statements and warnings (including pictograms) along with MSDSs will always have the same information located in the same place.  These changes are critical not only for everyday users of the chemicals but also emergency responders and medical personnel.

However, the changes won’t be required next week and probably not even next year.  The process for moving through a major revision to an established regulation can be long and loud (with input from all vantages points on the changes).  OSHA took the first step of this process in September 2006 with an “Advance Notice of Proposed Rulemaking” (ANPR).  The recent step, in September 2009, is detailing the changes to HazCom with the publishing of a “Notice of Proposed Rulemaking” (NPRM). Next is the comment period (90 days – December 29, 2009) and then public hearings scheduled for early 2010.  OSHA will then draft a Proposed Standard which will have to be reviewed by the Office of Management and Budget and will consult with the Small Business Administration.  The Proposal Standard will then get published in the Federal Register, and will most likely have a comment period.  FINALLY, OSHA will incorporate changes from comments into the Final Standard, which will be published in the Federal Register with the provisions taking effect over the following months or years.

It’s a long process.  Regulators don’t have the window of time to slumber.
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Topics: Emilcott, OSHA, DOT, health and safety, General Industry H&S, Construction H&S, EPA, Emergency Response, H&S Training, Hazardous Waste Management, HazCom, worker safety, Occupational Health, Occupational Safety, MSDS, Hazard Communication Standard, Occupational Training, Safety Training in Spanish

Swine Flu Update

Posted by Shivi Kakar

Sep 17, 2009 1:52:33 AM

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Topics: H&S Training, Occupational Health, Webinar, emergency response training, Occupational Training, Safety Training in Spanish, Swine Flu

10 Items You Need To Know About Water and Mold Damage In A Commercial Building

Posted by Shivi Kakar

Sep 1, 2009 2:37:34 AM

Mike Gfroehrer
1. The uncontrolled release of water may result in mold (fungi) growth in a previously non-water damaged area of a building if the water release is not adequately addressed within 48 hours of its occurrence. In addition to mold growth, water damaged can result in structural damage and support the proliferation of other types of biological organisms including dust mites, cockroaches, rodents, algae, and/or bacteria.

2. The uncontrolled release of water in a building with a history of water damage may cause dormant mold colonies from prior water releases to become active in less than 48 hours.

3. One of the most important factors in effectively preventing or controlling mold growth inside a commercial building is to have a written Water Response Plan in place before an uncontrolled release of water occurs.

4. An effective Water Response Plan will include provisions to immediately stop the uncontrolled release of water and prevent its’ reoccurrence.

5. An effective Water Response Plan will include provisions to immediately start removing the water by mechanical means such as extraction with wet vacuums and the use of commercial-grade drying equipment. Areas where drywall (sheetrock) are covered by large pieces of furniture, wallpaper, or cove base/moldings may require special attention that potentially includes removal of sections of the drywall. The source of the water (domestic drinking water vs. rain penetration through the building vs. widespread flooding vs. sewage backup) will also impact the required response activity. Visible inspection, moisture meters, infrared cameras, measurement of temperature and relative humidity are all tools that that may be used to identify where water damaged materials exist.

6. Depending on the capabilities of the commercial building’s maintenance staff, the Water Response Plan should anticipate the use of outside contractors such as licensed plumbers, roofing contractors, environmental consultants, water/fire damage restoration contractors, and/or qualified mold remediation contractors. It is advisable to have an established relationship with each type of contractor in order to best control costs once the Water Response Plan requires activation.

7. The most common health effect resulting from indoor mold exposure is an aggravation of allergies and/or asthmatic conditions. Prolonged exposure may cause hypersensitivity in some individuals, resulting in these individuals experiencing a severe respiratory reaction even when very low concentrations of airborne mold are present at work or at home. The variety of responses is often seen when employees working in the same area report a wide range of individual responses when near the water damaged building materials.

8. If an uncontrolled release of water is not properly responded to mold growth will likely result. Once mold growth is suspected or confirmed a qualified individual should conduct an investigation to determine the extent of the mold growth and develop a Mold Remediation Work Plan. The Mold Remediation Work Plan should identify procedures to follow when cleaning or removing mold damaged building materials so that building occupants are protected and not adversely affected by the remediation project.

9. The Mold Remediation Work Plan must include: which building materials require removal; which building materials require cleaning and disinfection; a plan for the isolation of the work area using barriers (polyethylene sheeting) and negative air machines to control airborne dust generation; documentation of worker training in proper mold remediation work procedures; and the criteria of the Post Remediation Assessment. Simply put, spraying with bleach or covering with an anti-microbial paint is not an appropriate response where mold growth is confirmed to be present on installed building materials.

10. A Post Remediation Assessment (PRA) determines if the Mold Remediation Work Plan was successful in returning the area to non-water damaged condition. The PRA must be conducted prior to the removal of isolation barriers and should include: a visual inspection to confirm water and mold damaged has been removed and the area has been appropriately cleaned; a moisture survey, using moisture meters, to document remaining installed building materials are satisfactorily dry; and confirmation that corrective actions are in place to prevent additional water damage. Depending on the extent of the mold damage air and surface samples may be collected as part of the PRA. Whenever air or surface samples are collected a qualified individual, such as a Certified Industrial Hygienist, should be chosen to determine the sample locations and assist with the interpretation of results.
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Topics: health and safety, Construction H&S, worker safety, Occupational Health, Occupational Safety, Mold, Occupational Training, Working Green, Water Response Plan

Watch Your Back! 5 Bending/Lifting Techniques

Posted by Shivi Kakar

Aug 27, 2009 8:10:22 AM

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Topics: health and safety, General Industry H&S, Construction H&S, H&S Training, Occupational Health, Occupational Training, Safety Training in Spanish

10 Things EVERYONE Should Know About Fire Safety

Posted by Shivi Kakar

Aug 25, 2009 5:09:58 AM

EHS Top Ten Tuesday: Fire Safety

Eileen Lucier
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Topics: OSHA, health and safety, General Industry H&S, H&S Training, Hazardous Materials, Occupational Health, Occupational Safety, Fire Safety, Occupational Training, Lab Safety, Medical Records, NFPA

Top Ten Things You Need to Know About Lab Safety

Posted by Shivi Kakar

Aug 18, 2009 10:30:46 AM

Laurie de Laski

1. The OSHA Standard for regulating hazardous chemicals in research and development laboratories is: Occupational Exposure to Hazardous Chemicals in Laboratories (29 CFR 1910.1450). The standard does not apply to production or QA/QC labs. Please refer to last week’s post for specific requirements of this standard.

2. Proper chemical handling and storage needs to be maintained in labs, including: appropriate spill control methods, separation of incompatible materials, flammable storage, chemical waste storage, dating of dangerous or short shelf life materials.

3. Hazard Assessments should be performed on new or highly hazardous operations or tasks. Basic lab procedures and controls may not be sufficient for some processes or chemicals.

4. Standard Operating Procedures (SOP) should be written for all lab practices. SOPs should include control methods, such as the type of personal protective equipment (PPE) to be used. SOPs can also used as part of the Chemical Hygiene program for R&D labs.

5. Chemical Fume Hoods must be available, maintained, and used properly. Hoods must be 100% exhausted and the type of hood is dependent on the chemicals and volumes to be used. Large equipment should not be placed in hoods, but should be provided with alternative local exhaust ventilation. Hood should be monitored and ventilation rates maintained within 20% of the approved face velocity.

6. Personal protective equipment (PPE) must be selected based on the Hazard Assessments conducted and should address all potential exposes to chemicals, infectious agents, or physical hazards (UV, lasers, sharps, etc.). A lab coat, safety glasses and exam-type nitrile gloves may be acceptable for small potential splashes of low hazard chemicals and biologicals, however, larger quantities, high hazard materials, or hazardous operations require additional PPE.

7. Emergency Equipment must be available and well maintained. This includes: spill kits, first aid kits, fire extinguishers, fire blankets, eye wash stations, emergency showers, and PPE. Emergency equipment should be inspected and/or tested at least monthly.

8. Cleaning and decontamination of lab surfaces and equipment should be conducted on a regular schedule. Surfaces, like lab benches and floors, with a high potential to have spilled chemical or biological materials, should be decontaminated at the end of each shift or immediately when contaminated. Other surfaces to consider are computer keyboards, mouse, cabinet and door knobs, equipment (including buttons and doors), and other surfaces that are handled, perhaps with gloves, during normal operations. These surfaces should be cleaned and decontaminated periodically.

9. Special hazards (radiation, lasers, and highly hazardous chemicals) require special controls and procedures. These special hazards should always have a specific SOP to address the additional controls needed, including: training of users and awareness of others in the lab, signs/warnings, special PPE, emergency equipment.

10. Training of lab workers is essential to control hazards and reduce accidents. Lab operations change frequently and it is important for the worker to understand the basics of hazard identification and control in addition to the specifics of the chemical, physical, and biological hazards they may be exposed to in the lab. Though the lab environment tends to be clean, there are many hazards and potential injuries that can occur, including life threatening ones. For example, the recent death of a post-grad student in a lab that spilled a highly flammable chemical on her clothes, and died of her burn injuries.
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Topics: OSHA, Personal Protective Equipment, health and safety, General Industry H&S, Emergency Response, H&S Training, Hazardous Waste Management, Lab Safety & Electrical, Occupational Training, Lab Safety

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